There is a new interpretation for Standard 12.6, based on USDOE expectations, that becomes effective in September 2025. Let’s start by figuring out who will be impacted. Based on the President’s Communique from June 2024, the first group of institutions to write to the new interpretation of 12.6 will be the Track B institutions in the reaffirmation class of 2026. Note that the Track B reaffirmation class of 2026 will be submitting the Compliance Certification in September 2025, so they will need to write to the new interpretation before it officially takes effect. The next reaffirmation group to be impacted should be the Track A class of 2027.
It is important to note that the interpretation specifically says, “Member institutions preparing a compliance certification for review during…decennial reaffirmation or review by a Fifth-Year Interim Committee…as part of a narrative…for Standard 12.6…” (emphasis added) “But wait”, you say, “Standard 12.6 is not part of the Fifth-Year Review. ” Correct, but given the wording in the interpretation, I advise everybody to keep an eye on this. If added to the Fifth-Year Interim report, the first groups through would be the class of 2030 for both track A and track B.
Now that we know the who, let’s talk about the what.
“Institutions are expected to document and demonstrate their success with respect to their financial literacy and debt management efforts.”
This new interpretation for 12.6 has a very familiar flavor. Remember the changes to 8.1 with the completion measure? This will work much the same way. Each institution will identify a Key Post-College Financial Indicator (from a list of nine) in early spring 2025, establish a threshold of acceptability and an aspirational goal for the indicator (justifying both), and then monitor the performance of students against these two numbers. Institutions falling below the threshold of acceptability are expected to, “…document ongoing efforts to improve their performance…” As long as an institution is above the threshold, no changes are necessary.
While multiple measures are encouraged, only one is required. The first measure on the list of nine choices is the cohort default rate, which (in my experience) many institutions already include in the narrative for 12.6. However, the establishing of thresholds and goals for a quantitative measure of student performance is a new thing for a standard in Section 12: Academic and Student Support Services.
Putting the usefulness or even appropriateness of the measure aside, I don’t think 12.6 is the right place for it. This is a quantitative measure of student achievement with what I call ongoing context. We already have the precedent for this type of measure in 8.1. Core Requirement 8.1 already has the ongoing context, the requirement of setting thresholds and aspirational goals, and requires action when the threshold is not attained. Why not cross-list 8.1 and 12.6 and put this measure of student achievement with the others?